Search - 制暴无限杀机 下载

CRA asserted that the competent authority proceedings did not result in binding agreements between Sifto Canada and CRA and, even if they did, they did not fix the arm’s length transfer price – so that CRA was not only authorized, but was required, by the ITA to issue the post-audit reassessments once in possession of the new audit information. ...

. … It is true that here there was an 8 1/2” x 14” on‑the‑shelf sign…[but] Costco was merely advertising the discount. ...

. … CRA’s analysis arrived at about 65:35. He also noted (at para. 16): Since they are co-parenting with shared parental responsibilities and the school and daycare are aware of the precise terms of their divorce order, it might be more appropriate to consider seven hours of each school day as 50:50 [rather than 100% to the mother]. ...

Miller J found (at para 32): … It is my view that in a GAAR appeal, draft documents prepared in the context of a taxpayer’s audit or considered by officials involved in or consulted during the audit and assessment of the taxpayer should be disclosed. ...

The Funds argued that they were receiving an exempt financial service from Funding Corp – so that this arrangement in effect eliminated the GST or HST on the portion of the management fees that was assigned to Funding Corp. ...

[T]here is no evidence that shows that the Appellant conveyed a beneficial interest in the aforementioned shares prior to the completion of the purchase and sale arrangement with his family member … [B]ecause the Appellant’s wife and daughters did not have an interest in the 85 Class B, C and D common shares prior to the time they purchased them from the Appellant later on the same day, no benefit was conferred on them directly or indirectly as a consequence of the completion of the capital reorganization of MDPC. ...

. … Essentially, all of the factors outlined in Essa [[1993] OJ No 229]… favour the granting of this motion. ...

Paris J accepted that a corporation (“SVO”) had agreed to manage all of the buildings as well as the common areas as agent for all of the owners, notwithstanding that the taxpayer was only able to provide an unsigned copy of the management agreement – and also accepted that a parking area had subsequently been acquired by SVO as their agent notwithstanding the failure to locate any written agreement to this effect. ...

. … In the circumstances, I have two choices. I can either not allow Ms. ...

. … The contrary conclusion would strain the ordinary meaning of the words “equal or near equal”. ...